The aggressive enforcement of the Foreign Corrupt Practices Act (FCPA) by the Department of Justice and the Securities and Exchange Commission shows no signs of abating, as newly-appointed Administration officials have expressed their commitment to continuing the emphasis of the two prior administrations.  The government appears to be poised to continue the FCPA Pilot Program that DOJ’s Fraud Section introduced in April 2016, which resulted in a flurry of settlements over the last year with their attendant billions of dollars in fines and penalties.  As the enforcement agencies’ experience prosecuting FCPA violations grows, so too does their level of sophistication and thus, their expectation of companies’ compliance programs.  It will no longer suffice to have an FCPA compliance program on paper and periodically train employees about it – the government expects companies operating in higher-risk geographies to actually monitor compliance and to prevent and detect violations.  One of the key methods by which companies do this is via anti-corruption internal audits.

The presenters of this webcast are experienced in the design and performance of such anti-corruption audits, as well as in remediating findings arising from such audits.  The webinar, while providing an overview of the key considerations of anti-corruption audits, will also address some of the practical challenges facing organizations that may be considering them for the first time, such as:

  • Which countries should be included in compliance assessment efforts, and why?  How many should be done, and how often?
  • Who should lead the audits, and should lawyers be involved?  Why?  Can an internal audit be performed under privilege?
  • When should anti-corruption audits be scheduled, and what should their scope be?
  • How can organizations keep audit costs down while getting ‘bang for the buck?’
Faculty Member
David Wilson
Thompson Hine

David Wilson is a partner at the law firm of Thompson Hine LLP and is the partner-in-charge of the firm’s Washington, D.C. office. David helps companies design and implement programs for international anticorruption compliance, and has traveled around the world to investigate corruption allegations, assess company compliance programs, and train company employees and third party agents. He has represented clients in dozens of investigations conducted by the Securities and Exchange Commission, congressional committees, and various federal agencies, including the U.S. Department of Justice. David is a graduate of Georgetown Law Center.

Faculty Member
Bernie Woolfley

Bernie Woolfley, CPA, CFF, CFE, is a Managing Director at Navigant who has led and managed numerous forensic accounting investigations, including a number of projects involving the investigation and analysis of alleged violations of anti-bribery and corruption statutes. As part of his work on these engagements, Mr. Woolfley has led Navigant’s efforts on a number of anti-bribery investigations both in the U.S. and in numerous foreign countries. Through his work on these matters, he has developed a detailed knowledge of how to investigate and trace various types of business and accounting transactions to identify the sources and uses of misappropriated funds. He is a graduate of William and Mary.

CLE Credits (Law)

NALA--Credit not available
NFPA--Credit not available
AL1.3 General
AK1.25 General
ARNot Available General
AZ1.25 General
CA1.25 General
CO1.5 General
CT1.25 General
DE1.3 General
FL1.5 General
GA1.3 General
HI1.25 General
IA1.25 General
ID1.25 General
IL1.25 General
IN1.25 General
KSNot Available General
KY1.25 General
LA1.25 General
ME1.25 General
MN1.25 General
MO1.5 General
MS1.3 General
MT1.25 General
NC1.25 General
ND1.25 General
NENot Available General
NH1.25 General
NJ1.5 General
NM1.25 General
NV1 General
NY1.5 General
OH1.3 General
OK1.5 General
OR1.25 General
PA1 General
RINot Available General
SCNot Available General
TN1.25 General
TX1.25 General
UT1 General
VANot Available General
VT1.25 General
WA1.25 Law and Legal Procedure
WI1.5 General
WV1.5 General
WY1.25 General

In some CLE states, the course will be submitted to the bar after you register. If for any reason the course is not approved, we will fully refund your registration fee. If a state is listed on this course, then we are confident the course fits that state's standards and already is or will be approved for credit.

Compliance Credits


For Compliance courses, we have listed the credit we believe this course is eligible for. After completing the course, you will receive instructions for submitting the course to the Compliance Certification Board (CCB). This education activity has not been submitted to the Compliance Certification Board (CCB)®for review or approval of its educational content. Please [email protected] directly regarding the applications and documentation necessary to submit applicable compliance related education to CCB for their review.

100% of attendees recommend this webinar

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4 out of 5


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